Regulation 5 Specified relevant transfer pricing records

(1)

The following are specified relevant transfer pricing records for the purposes of section 12B of TMA 1970 and paragraph 21 of Schedule 18 to the Finance Act 1998—

(a)

the records listed in column 1 of the table, and

(b)

any other records specified in a notice published in accordance with paragraph (4).

(2)

Except where regulation 6 applies, the records listed in the table must—

(a)

contain the information described in the documents referred to in column 2 of the table, and

(b)

be kept and preserved in the form and manner set out in those documents.

(3)

The table for the purposes of paragraph (1) and (2) is as follows.

Column 1	Column 2
The Local File	Annex II to Chapter V of the transfer pricing guidelines^f1.
The Master File	Annex I to Chapter V of the transfer pricing guidelines^f2.

(4)

The Commissioners for His Majesty’s Revenue and Customs may specify in a published notice—

(a)

supplementary information relating to the preparation of the Local File, and

(b)

the form and manner in which that information is to be kept and preserved.

Annotations

Footnotes

f1: Annex II to Chapter V of the transfer pricing guidelines can be found here: https://read.oecd-ilibrary.org/taxation/oecd-transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations-2022_0e655865-en#page547.
f2: Annex I to Chapter V of the transfer pricing guidelines can be found here: https://read.oecd-ilibrary.org/taxation/oecd-transfer-pricing-guidelines-for-multinational-enterprises-and-tax-administrations-2022_0e655865-en#page545.